Can a Financial Aid Administrator Determine a Student Does Not Have Homeless Youth Status?

Scenario: We have a determination of unaccompanied homeless youth status (UHY) from the director of a homeless shelter. We, however, have determined the student does not have UHY status.

Answer: Effective with the 2023-24 award year, in making a determination of independence based on homelessness under Section 479D of the Higher Education Act of 1965 (HEA), as amended, [20 USC 1087uu-2(a)], as clarified in Dear Colleague Letter GEN-23-06, a financial aid administrator (FAA) shall accept documentation from the following designated authorities--provided through a documented phone call, written statement, or verifiable electronic data match:

• A local educational agency homeless liaison, as designated by the McKinney-Vento Homeless Assistance Act (42 U.S.C. 11432(g)(1)(J)(ii))), or a designee of the liaison;
• The director or designee of an emergency or transitional shelter, street outreach program, homeless youth drop-in center, or other program serving individuals who are experiencing homelessness;
• The director or designee of a program funded under subtitle B of title IV of McKinney-Vento (relating to emergency shelter grants) (42 U.S.C. 11371 et seq.);
• The director or designee of a Federal TRIO program or a Gaining Early Awareness and Readiness for Undergraduate program (GEAR UP) grant; or
• An FAA at another institution who documented the student’s circumstance in the same or a prior award year.

If the student has a determination from the director of a homeless shelter, the FAA cannot make the determination that the student does not have UHY status. The Application and Verification Guide, Chapter 5 of the FSA Handbook indicates it is not conflicting information if you disagree with an authority’s determination that a student is homeless or at risk of homelessness. If you believe the authority is incorrect or abusing the process, accept their determination, but contact the local homeless liaison or Director of a RHYA/HUD funded shelter to evaluate the authority’s determinations.

When a student cannot provide documentation from one of the above parties, the homeless youth determination must be made by the FAA. It may be made on a case-by-case basis using a written statement from or a documented interview with the student that confirms the unaccompanied homeless youth or at risk of homelessness status. This determination must be made without regard to the reason for the student's situation.

Note: Effective with the 2023-24 award year, any student determined to be independent due to homelessness for a preceding award year shall be presumed to be independent for each subsequent award year at the same institution, unless the student indicates a change in circumstances or unless conflicting information exists. For guidance changes on the carryover of the homelessness determination, reference Section 479D(d)(1) of the Higher Education Act of 1965 (HEA), as amended, [20 USC 1087uu-2(d)(1)] and Dear Colleague Letter GEN-22-15.

Tools: Refer to the following tools to assist with this student population:

• Tip Sheet for Unaccompanied Homeless Youth (UHY)
• Homelessness--Unaccompanied Homeless Youth Determinations: 2023-24 Template
• Homelessness--Unaccompanied Homeless Youth Determinations: 2024-25 Template

Student Aid Reference Desk: For additional information, try the Student Aid Reference Desk. It is a central hub of all the important financial aid resources you need with direct links to legislation, regulation, Dear Colleague Letters, and other ED and NASFAA references. It is updated on a rolling basis with the latest news and changes.